843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902.  Is any further authorization needed to conduct such transactions following these actions?

No.  General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902.  Further authorization from OFAC beyond GL L is not required under E.O. 13902, so long as such transactions and activities are authorized pursuant to a general license or a specific license under the ITSR, including for humanitarian-related transactions and activities authorized pursuant to the ITSR that are not covered by the exception in Section 11 of E.O. 13902.  

Any transactions otherwise prohibited by the ITSR or any other part of 31 C.F.R. chapter V must be separately licensed, as appropriate.